Hayes Holderness

Visiting Assistant Professor of Law and Ribstein Fellow


Hayes Holderness joined the College of Law as a Ribstein Fellow in the fall of 2015. Professor Holderness focuses his scholarship on issues of state and local taxation. Specifically, he is interested in the interaction between multiple overlapping levels of governmental jurisdiction and the effect of mobile taxpayer and tax bases on systems of taxation.

Professor Holderness teaches classes covering federal and state and local taxation. He is a consistent contributor to major publications in the field of state and local taxation and his article, Revenue Departments’ Cloudy Minds Lead to Wrong Answers, is included in Professor Richard D. Pomp’s leading casebook, State and Local Taxation.

Professor Holderness received his JD cum laude, and LLM in Taxation from the New York University School of Law. Before entering law teaching, he served as a Tax Policy Fellow for the United States Congress’ Joint Committee on Taxation, where he assisted in the drafting and analysis of proposed federal tax legislation. Professor Holderness was also a practicing attorney as a member of the state and local tax group of McDermott Will & Emery LLP, where he worked on a variety of tax matters.


JD, LLM New York University School of Law

Areas of Expertise

State and Local Taxation
Federal Taxation (Corporate, Partnership, Individual)
Tax Administration
Tax Salience


Income Taxation
State and Local Taxation

Selected Publications

The Unexpected Role of Tax Salience in State Competition for Businesses, 84 U. Chi. L. Rev. __ (forthcoming 2017) [SSRN]

Taking Tax Due Process Seriously: The Give and Take of State Taxation, 19 Fla. Tax Rev. __ (forthcoming 2017) [SSRN]

Revenue Departments’ Cloudy Minds Lead to Wrong Answers (revised), in Richard D. Pomp, State and Local Taxation (8th ed. 2015), originally in New York University Institute on State and Local Taxation—2013 (Matthew Bender & Co., Inc., pub.), at 6-1 (2013)

Taxing Privacy, 21 Geo. J. on Poverty L. & Pol’y 1 (2013) [SSRN]

Note, Price Includes Tax: Protecting Consumers from Tax-Exclusive Pricing, 66 N.Y.U. Ann. Surv. Am. L. 783 (2011) [SSRN]